www.morganlewis.com Morgan, Lewis & Bockius LLP

Management of TENORM

Practical Assessment

Ted Bosquez

(May 13, 2014)
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• OVERVIEW

• OIL AND GAS OPERATIONS

– REGIONAL CONSIDERATIONS

– REGULATION

• LOOKING AHEAD

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Overview

• The Earth itself is radioactive, and the ground contains a

variety of radioactive isotopes.

• This naturally occurring radioactive material (NORM) is

typically composed of one or more of the following elements:

– Radium and its Decay Products

– Uranium and its Decay Products (including Radon)

– Thorium and its Decay Products

– Lead-210

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Overview

• The metals usually do not exist in their free metallic form but

are found in the geology as salts.

• Uranium salts are generally not soluble in water, but radium

salts are. The water existing within the rock formations, called

produced water, has high concentrations of both salts – hence

the term "brine water" – and radioactivity.

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Overview

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Overview

• This natural radiation is not a cause for concern as it

contributes to normal background radiation.

• Industrial operations, however, may concentrate NORM and

produce technologically enhanced naturally occurring

radioactive material (TENORM).

• TENORM may pose a higher risk to humans as a result of the

higher concentrations of radioactive materials.

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Oil and Gas Operations

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Oil and Gas Operations

• Natural gas deposits tend to have

higher concentrations of radioisotopes.

• The elevated presence of radioactive

material assists geologists in their

efforts to identify natural gas deposits.

• The presence of NORM also raises

operational considerations if the site is

selected for active drilling and

production.

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Oil and Gas Operations

When a well is installed, NORM can come to the surface in several

ways:

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− Drilling Fluid - during the drilling

process, the rock cuttings must be

removed so drilling can continue. To

this end, drilling fluid is used to bring

the rock cuttings to the surface. The

drilling fluid can be a liquid, a gas, or

a combination of the two. Drilling

fluid is usually a mud-like substance

that contains the rock cuttings, which

may have radioactive solids, and

formation water, which likely has

radioactive salts.
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– Hydraulic Fracturing – anywhere from 10 to 40 percent of the water

used in hydraulic fracturing comes back up the well carrying formation

water and concentrations of salts that dissolve in the fracturing water,

which may include NORM.

– Production – produced water, which may contain high concentrations of

salts and radioactive material, is brought to the surface along with the

extracted gas and oil. It is also possible that radon gas may be

extracted along with the natural gas.

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Oil and Gas Operations

When a well is operated, NORM may be concentrated into TENORM in

several ways:

– Scale – salts have a specific solubility in water. Once that solubility level

is reached, no more of that salt will dissolve in the water. Excess salt –

including radioactive salts – will precipitate out on nearby solid surfaces,

including the well head and casing. Other areas that can have

radioactive scale deposits include the water lines associated with

separators, heater treaters, and gas dehydrators.

– Sludge – sludge is composed of dissolved (potentially radioactive) salts

that precipitate from produced water as its temperature and pressure

change.

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Oil and Gas Operations

– Recycling Water – radioactive salts are not easily filtered out of water.

So, each time the water is sent down the well, the concentration of

radioactivity in the water increases. In addition, if chemical scale

inhibitors are used, the concentration of radioactivity remains in the

water.

– Operators use recycled water in many different ways in an effort to be

environmentally conscious and efficient, but these practices may have

unintended consequences.

• For example, operators routinely spray recycled water on unpaved

roads several times a day as a dust suppressant, which could

expose workers and the environment to increased radiation levels.

In the winter, recycled water can also be sprayed on roadways to

de-ice the roads, having a similar result.

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– Filters – often cloth or bag filters are employed in the process of

cleaning the water before reuse. The fine sediment that collects in the

screen or filter may contain elevated radioactivity.

– Separation Pits – separation pits are used to divide the solids, including

drill cuttings, and from the liquids – produced water and drill fluid. As the

solids settle out, they may contain increased concentrations of

radioactive material. The liquids may also have increased radioactive

concentrations.

– Shale Shakers – a similar concept to the separation pits, shale shakers

are used to separate solid and liquid wastes. Both the liquid and solids

may contain elevated radioactivity.

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– Equipment – as a result of work processes that spread radioactivity over

the work site, the equipment can become contaminated with radiation.

Gas processing equipment with the highest radiation levels includes

reflux pumps, propane pumps and tanks, and more.

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